FRCS tightens transfer pricing checks

Fiji Revenue and Customs Service (FRCS) is strengthening its measures against the increasing use of transfer pricing by companies, particularly those with overseas affiliations. The issue was highlighted by Sakiusa Tubuna, Chair of the Standing Committee on Economic Affairs, during the presentation of the FRCS Annual Report for 2024–2025.

FRCS Chief Executive Udit Singh stated that Fiji is enhancing its efforts to tackle international tax issues, including transfer pricing. The service has become a member of the Base Erosion and Profit Shifting (BEPS) framework and the Global Forum, which comprises approximately 170 member countries. This membership facilitates information exchange, which will become automatic by 2027–28.

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We are now manually exchanging information and soon, in 2027–28, to move to automatic exchange of information. So this means that companies that are operating in mutual jurisdictions will be sharing information.

This move towards automatic exchange of information will enable Fiji to access crucial data on companies operating across different jurisdictions. It will provide insights into their overseas structures and the taxes they are remitting. FRCS Director Corporate Services Shavindra Nath confirmed that manual tax information exchange is already occurring, with automation slated for completion by the end of next year. This aligns with Fiji's commitment following its removal from the European Union's blacklist.

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While we have signed the agreement of the Global Forum, we have to implement the automatic exchange of information, or we call it CRS, and then there will be an exchange of information between 150 or 170 countries automatically.